This is in response to a letter from your office dated September 12, 2018, which transmitted the referenced second appeal on behalf of the Town of Warwick (Applicant). The Applicant is appealing the Department of Homeland Security’s Federal Emergency Management Agency’s denial of $316,997.60 related to construction of a replacement culvert. As explained in the enclosed analysis, I have determined that the Applicant did not obtain approval from FEMA prior to making the changes to the approved scope of work. In addition, the Applicant has not demonstrated that the upgrades to the culvert were required by codes and standards. Accordingly, I am denying the appeal. Please inform the Applicant of my decision. This determination is the final decision on this matter pursuant to 44 C.F.R. § 206.206, Appeals.